Justia U.S. 8th Circuit Court of Appeals Opinion Summaries

Jeremy Young was convicted by a jury of possessing an unregistered firearm and being a felon in possession of a firearm. He was also convicted by a separate jury of assaulting a federal officer. Young received a total sentence of 84 months’ imprisonment and 3 years of supervised release. He appealed, challenging the Government’s use of peremptory strikes against Native American venirepersons, the district court’s decision to admit certain evidence as res gestae, and the sufficiency of the evidence at both trials.The United States District Court for the District of South Dakota denied Young’s Batson challenges, finding the Government’s reasons for striking the Native American jurors to be legitimate and race-neutral. The court also admitted excerpts of Young’s recorded interview with Agent Kumley, where Young discussed his plans to transport methamphetamine, as relevant res gestae evidence. The jury found Young guilty on all counts.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s rulings. The appellate court found no clear error in the district court’s Batson analysis, noting that the Government provided race-neutral reasons for striking the jurors and that Young failed to demonstrate pretext. The court also upheld the admission of the recorded interview, agreeing that it provided relevant context for Young’s possession of the shotgun. Finally, the court concluded that the evidence was sufficient to support Young’s convictions, as the jury reasonably found that Young had both actual and constructive possession of the firearm and that he intentionally assaulted Sergeant Antoine. View "United States v. Young" on Justia Law

Isak Aden's ex-girlfriend called 911 on July 2, 2019, reporting that Aden had pointed a gun at her and ordered her to drive. She escaped, and Aden fled into a wooded area. Officers found Aden holding a gun to his head and began negotiating with him. Despite multiple attempts to get him to surrender, Aden refused and moved closer to his gun. Officers devised a tactical plan involving flashbangs and foam bullets to disorient Aden and arrest him. When the plan was executed, Aden reached for his gun, and officers fired lethal rounds, resulting in his death.The United States District Court for the District of Minnesota partially denied the defendants' motion for summary judgment, finding that the officers were not entitled to qualified or official immunity and that the City of Eagan could be liable under Monell. The court dismissed some claims but allowed others to proceed, leading to the current appeal.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the officers' actions were reasonable under the circumstances and that they did not violate Aden's constitutional rights. The court held that the officers were entitled to qualified immunity because their use of force was not excessive. The court also found that the City of Eagan was not subject to Monell liability because there was no constitutional violation by the officers. Additionally, the court held that the officers were entitled to official immunity under Minnesota law, and thus, the City of Eagan was also entitled to vicarious official immunity.The Eighth Circuit reversed the district court's partial denial of summary judgment and remanded the case for entry of summary judgment based on qualified and official immunity. View "Aden v. City of Eagan" on Justia Law

Betty Grooms, a Missouri clerk of court, filed a lawsuit under 42 U.S.C. § 1983 against Alice Bell and Judge Steven Privette, alleging violations of her First Amendment rights through discrimination and retaliation, and violations of her substantive due process rights. Grooms, a Republican, had defeated Bell, a Democrat, in an election for Circuit Clerk. Bell, who retained her job under Grooms, later married Privette, a Republican judge. Tensions arose when Bell and Privette were uncooperative with Grooms, leading to Bell's resignation and announcement to run for Circuit Clerk. Privette ordered Grooms to prepare detailed spreadsheets, which he repeatedly rejected, and initiated a contempt prosecution against her, which was eventually dismissed by the Missouri Supreme Court.The United States District Court for the Western District of Missouri dismissed Grooms's claims, ruling that the defendants did not violate her clearly established First Amendment rights and did not violate her substantive due process rights. The court found that the defendants' actions did not constitute adverse employment actions under clearly established law and that Grooms did not suffer a serious deprivation of a protected interest.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that Bell and Privette were entitled to qualified immunity on the First Amendment claim, as Grooms failed to show that their actions constituted adverse employment actions under clearly established law. Additionally, the court found that Grooms's substantive due process claim was inadequate, as she did not demonstrate a serious deprivation of a protected interest. The court concluded that the defendants' conduct did not shock the conscience and did not violate Grooms's substantive due process rights. View "Grooms v. Privette" on Justia Law

Fourteen civilly committed clients of the Minnesota Sex Offender Program (MSOP) filed a lawsuit challenging MSOP policies that affected their spiritual group activities, particularly those impacted by the COVID-19 pandemic. Before the pandemic, MSOP allowed clients to participate in spiritual groups under certain conditions. However, during the pandemic, MSOP implemented new regulations that restricted these activities. Plaintiffs argued that these restrictions violated the U.S. Constitution and the Religious Land Use and Institutionalized Persons Act (RLUIPA).The United States District Court for the District of Minnesota granted summary judgment in favor of the defendants, finding that the plaintiffs' claims were moot because the COVID-19 restrictions had been lifted, and pre-pandemic policies were reinstated. The court also declined to address new concerns raised by the plaintiffs regarding MSOP's current policies, as these issues were not included in the second amended complaint.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that the plaintiffs' claims about the pandemic-era policies were moot since those policies were no longer in effect. The court also found that the plaintiffs' new concerns about MSOP's current policies were not properly pled in the second amended complaint and thus were not before the court. Additionally, the appellate court denied the plaintiffs' motion to supplement the record with discovery documents, as the plaintiffs failed to provide a valid reason for not including these documents earlier, and their inclusion would not change the case's resolution. View "Allan v. Minnesota DHS" on Justia Law

Marcus Todd, a state employee in Minnesota, alleged that a union violated his First and Fourteenth Amendment rights by deducting union dues from his paycheck without his consent. Todd joined the American Federation of State, County, and Municipal Employees in 2014 and authorized dues deductions. In 2018, a new authorization card was allegedly signed electronically with Todd's name, which he claims was forged. After the Supreme Court's decision in Janus v. American Federation of State, County, and Municipal Employees, Council 31, Todd attempted to resign from the union and stop dues deductions, but the union continued until May 2021, citing an annual opt-out period.The United States District Court for the District of Minnesota dismissed Todd's federal claims, stating that he voluntarily agreed to the dues deductions before Janus and was contractually bound to the opt-out period. The court also found that the union did not act under color of state law regarding the alleged forgery and dismissed Todd's claims for prospective relief as moot. The court declined to exercise jurisdiction over Todd's state law claims.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that Todd's claims failed due to the lack of state action, as the union's actions were based on private agreements, not state statutes. The court referenced Hoekman v. Education Minnesota and Burns v. School Service Employees Union Local 284, which established that private agreements for dues deductions do not constitute state action. The court also found that the alleged forgery did not establish state action, as it was a private misuse of state law. Consequently, the Eighth Circuit affirmed the district court's judgment. View "Todd v. AFSCME" on Justia Law

Jennifer Harmon’s son, N.J., died by suicide while residing at the Bruce Normile Juvenile Justice Center (BNJJC) under the care of the Second Judicial Circuit of Missouri. Harmon filed a lawsuit seeking damages for her son’s death, including various 42 U.S.C. § 1983 and state wrongful death claims against the Second Circuit, several named defendants from both the Second Circuit and BNJJC, Preferred Family Healthcare (PFH), and several named defendants from PFH. All defendants filed motions to dismiss for failure to state a claim.The United States District Court for the Eastern District of Missouri granted the Second Circuit and Government Defendants’ motion to dismiss. The court found that the claims against the Second Circuit were barred by the Eleventh Amendment, the § 1983 claims against the Government Defendants were barred by qualified immunity, and the state tort claims against the Government Defendants were barred by official immunity. Harmon appealed these immunity judgments.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court’s dismissal of Harmon’s claims against the Second Circuit, holding that the Second Circuit is not a “person” amenable to suit under § 1983 and is entitled to Eleventh Amendment immunity, which Missouri has not waived. The court also affirmed the dismissal of Harmon’s § 1983 claims against the Government Defendants, concluding that the Government Defendants were entitled to qualified immunity because Harmon failed to show that any constitutional violation was clearly established. Lastly, the court affirmed the dismissal of Harmon’s state tort claims against the Government Defendants, holding that the Government Defendants were entitled to official immunity under Missouri law because Harmon failed to plead both the existence of a department-mandated policy and a breach of that policy. View "Harmon v. Second Judicial Circuit of the State of Missouri" on Justia Law

Amity Dimock, the mother of Kobe Dimock-Heisler, sued the City of Brooklyn Center and four police officers, alleging unconstitutional warrantless entry and use of deadly force. The incident began when Kobe's grandfather, Erwin Heisler, called 911 reporting that Kobe had threatened him with a knife and hammer. When officers arrived, they entered the home without a warrant, leading to a confrontation where Kobe, holding a knife, was shot and killed by officers.The United States District Court for the District of Minnesota granted summary judgment in favor of the officers, citing qualified immunity. The court found that the officers reasonably believed exigent circumstances justified their warrantless entry and that they had probable cause to believe Kobe posed an immediate threat, justifying the use of deadly force. Dimock appealed the decision, challenging the grant of qualified immunity.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court affirmed the district court's decision, holding that the officers were entitled to qualified immunity. The court determined that the officers' belief in the existence of exigent circumstances was reasonable given the information they had, including Kobe's previous threats and mental health history. Additionally, the court found that the use of deadly force was justified as the officers had probable cause to believe Kobe posed an immediate threat to his grandmother and the officers, even though Kobe was only holding the knife and not actively attacking anyone at the moment of the shooting. The court concluded that the rights asserted by Dimock were not clearly established in this context, thus affirming the summary judgment in favor of the officers. View "Dimock v. City of Brooklyn Center" on Justia Law

Kyle J. Dalen was civilly committed but not taken into custody. Five months later, he was arrested for felony harassment and stalking and placed in county jail. Dalen sued, alleging pretrial punishment, unreasonable restraint, and deliberate indifference to his medical needs. The district court dismissed his complaint, and Dalen appealed.The United States District Court for the District of Minnesota dismissed Dalen's complaint, concluding that he failed to plausibly allege his claims under federal law. Dalen argued that the district court improperly dismissed his claim of deliberate indifference in violation of the Fourteenth Amendment’s Due Process Clause. He also claimed that the defendant’s failure to transfer him from jail to a treatment facility was punitive and that his detention constituted unreasonable restraint.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that Dalen's complaint lacked sufficient facts to support an objectively serious medical need, as required to prove deliberate indifference. The court also found that Dalen failed to show that his detention conditions were intentionally punitive or not reasonably related to a legitimate governmental purpose. Additionally, the court determined that Dalen did not provide specific facts about how he was restrained, which is necessary to support a claim of unreasonable restraint.The Eighth Circuit affirmed the district court's dismissal of Dalen's claims, concluding that he did not meet the necessary legal standards to proceed with his lawsuit. View "Dalen v. Harpstead" on Justia Law

Tad Mayfield, a nonpartisan legislative specialist in the assistant chief clerk’s office of the Missouri House of Representatives, was terminated on August 6, 2020, after sending an email on August 3, 2020, to the Speaker of the House and the President Pro Tem of the Missouri Senate advocating for mandatory face masks in the state capitol building due to COVID-19 concerns. Mayfield filed a lawsuit under 42 U.S.C. § 1983, alleging wrongful termination in retaliation for his email, claiming it violated his First Amendment rights.The case proceeded to a jury trial in the United States District Court for the Western District of Missouri. The jury found in favor of Mayfield, awarding him $15,000 in punitive damages and $14,993.93 in actual damages for lost wages. The district court denied the defendants' motions for judgment as a matter of law and awarded Mayfield attorney’s fees.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court’s decision, holding that Mayfield’s email was protected speech under the First Amendment as it addressed a matter of public concern. The court found that the defendants failed to show that the email had an adverse impact on the efficiency of the House’s operations, which would have necessitated a Pickering balancing test. The court also upheld the jury’s finding that the email was a substantial or motivating factor in Mayfield’s termination and rejected the defendants' claim of qualified immunity, stating that the right to speak on matters of public concern was clearly established.Additionally, the court found sufficient evidence to support the submission of punitive damages to the jury, given the defendants' knowledge that terminating an employee for raising public health concerns could be illegal. The court also upheld the district court’s award of attorney’s fees to Mayfield, finding no abuse of discretion. View "Mayfield v. Miller" on Justia Law

Matthew Cartia and Autumn Adams were arrested by officers when they attempted to interfere with a police investigation at Cartia's parents' house. The officers claimed that Cartia and Adams were interfering with their work, leading to a confrontation where Cartia was handcuffed and taken down using a "hip-toss" maneuver. Adams was also arrested after she tried to intervene. Both Cartia and Adams alleged that the officers used excessive force during and after their arrests, including claims that Cartia was struck and choked by the officers.The United States District Court for the Eastern District of Missouri granted summary judgment in favor of the defendants, including the officers and Lincoln County. The magistrate judge concluded that the officers were entitled to qualified immunity and that Lincoln County was not liable under Monell for the officers' actions.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court affirmed the grant of summary judgment for some claims but reversed it for others. The court held that the officers were entitled to qualified immunity for most of their actions, including the initial takedown and restraint of Cartia, as well as the force used against Adams. However, the court found that there were genuine issues of material fact regarding the excessive force claims against Officers Beeman and Gugliano for allegedly striking and choking Cartia after he was subdued. These claims were remanded for further proceedings. The court also found that the state law claims of assault and battery and negligence against these officers should proceed to trial, as there was sufficient evidence to suggest they may have acted with malice or bad faith. The court affirmed the dismissal of the remaining claims. View "Cartia v. Beeman" on Justia Law